Latest Documents


  • 3-July-2018

    English

    OECD releases BEPS discussion draft on the transfer pricing aspects of financial transactions

    Public comments are invited on a discussion draft on financial transactions, which deals with follow-up work in relation to Actions 8-10 ("Assure that transfer pricing outcomes are in line with value creation") of the BEPS Action Plan.

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  • 28-June-2018

    English

    Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines

    Public comments received on the scope of the future revisions of Chapter IV (Administrative Approaches) and Chapter VII (Intra-group services) of the Transfer Pricing Guidelines

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  • 21-June-2018

    English

    OECD releases new guidance on the application of the approach to hard-to-value intangibles and the transactional profit split method under BEPS Actions 8-10

    Today, the OECD released two reports containing Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles under BEPS Action 8; and Revised Guidance on the Application of the Transactional Profit Split Method under BEPS Action 10.

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  • 21-June-2018

    English

    Guidance for Tax Administrations on the Application of the Approach to Hard-to-Value Intangibles - BEPS Action 8

    The new guidance is aimed at reaching a common understanding and practice among tax administrations on how to apply adjustments resulting from the application of the approach to hard-to-value intangibles (HTVI). This guidance should improve consistency and reduce the risk of economic double taxation by providing the principles that should underlie the application of the HTVI approach.

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  • 21-June-2018

    English

    Revised Guidance on the Application of the Transactional Profit Split Method - BEPS Action 10

    This report contains revised guidance on the profit split method, developed as part of Action 10 of the BEPS Action Plan. This guidance will be incorporated into the OECD Transfer Pricing Guidelines, replacing the previous text on the transactional profit split method in Chapter II.

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  • 9-May-2018

    English

    OECD invites public comments on the scope of the future revision of Chapter IV (administrative approaches) and Chapter VII (intra-group services) of the Transfer Pricing Guidelines

    Public comments are invited on the future revision of Chapter IV, “Administrative Approaches to Avoiding and Resolving Transfer Pricing Disputes” of the Transfer Pricing Guidelines, and the future revision of Chapter VII, “Special Considerations for Intra-Group Services”, of the Transfer Pricing Guidelines.

  • 9-April-2018

    English

    Transfer Pricing Country Profiles

    These country profiles focus on countries' domestic legislation regarding key transfer pricing principles, including the arm's length principle, transfer pricing methods, comparability analysis, intangible property, intra-group services, cost contribution agreements, transfer pricing documentation, administrative approaches to avoiding and resolving disputes, safe harbours and other implementation measures.

  • 9-April-2018

    English

    OECD releases 14 additional country profiles containing key aspects of transfer pricing legislation

    The OECD has published 14 new and 2 updated transfer pricing country profiles, reflecting the current transfer pricing legislation and practices of participating countries. The country profiles, which are now available for 44 countries, contain up-to-date and harmonised information on key aspects of transfer pricing legislation, provided by countries themselves.

  • 22-March-2018

    English

    OECD releases additional guidance on the attribution of profits to a permanent establishment under BEPS Action 7

    The additional guidance resulting sets out high-level general principles, which countries agree are relevant and applicable in attributing profits to PEs in accordance with applicable treaty provisions. It also provides examples on the attribution of profits to certain types of PEs arising from the changes to the PE definition under BEPS Action 7.

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  • 22-March-2018

    English

    Additional Guidance on the Attribution of Profits to a Permanent Establishment under BEPS Action 7

    This report contains additional guidance on the attribution of profits to permanent establishments resulting from the changes in the Report on BEPS Action 7 to Article 5 of the OECD Model Tax Convention.

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